November 3, 2023

Comment Letter Analysis | CAQ Analysis of PCAOB Proposed Auditing Standard – General Responsibilities of the Auditor in Conducting an Audit and Proposed Amendments to PCAOB Standards (AS 1000)

On March 28, 2023, the Board issued for public comment a proposal for a new standard, AS 1000, General Responsibilities of the Auditor in Conducting an Audit. Comment letters were due May 30, 2023.

The PCAOB received 28 comment letters, with more than half from accounting firms and related groups.

Who responded?

AS 1000 Responses

In our analysis of comment letters received, key themes are:

  1. The proposal expands the auditor’s responsibilities despite the Board’s statement that the amendments were clarifications of existing standards.
  2. The proposal eliminates key concepts and principles from the extant standards
  3. The proposal creates confusion about the auditor’s role and will have other unintended consequences
  4. Accounting firms and related groups, among other commenters, oppose the clarification of the meaning of fair presentation and state it is important that the auditor’s evaluation of the presentation of the financial statements be applied within the applicable financial reporting framework.

For more details, read our full analysis here.